Op-Subs May Export Fees, Rates Sans Regard to Host’s Usury Laws
August 25, 2008
Interest rates and fees that may be imposed by an operating subsidiary of a national bank should be based on the usury laws of the parent bank’s home state, even though the operating subsidiary has no offices in that home state, according to the Office of the Comptroller of the Currency. In a recent interpretive letter, the OCC concluded that the bank’s operating subsidiary should be able...